Legal & privacy

Privacy Policy

How we handle information across the Incentive Management platform.

Effective date
22 July 2026
Last updated
22 July 2026

Introduction

Welcome to Incentive Management.

Incentive Management is a multi-organization business application designed to help participating organizations manage employee incentive programs, incentive calculations, approval workflows, targets, performance information, and related analytics.

This Privacy Policy explains how TOLARAM AFRICA ENTERPRISES LIMITED (“we,” “us,” or “our”) collects, uses, processes, stores, and protects information when authorized users access or use the Incentive Management mobile application and related services.

By using the application, you acknowledge the practices described in this Privacy Policy.

Information We May Collect

The information processed through Incentive Management depends on the organization you belong to, your assigned role, and the features enabled for your organization.

Account and Identity Information

We may process information required to identify and authenticate authorized users, including:

  • Employee name
  • Employee ID or employee code
  • Business email address
  • Registered mobile number
  • Organization information
  • Branch, department, team, or business unit
  • User role and access permissions
  • Authentication and login information

Where Microsoft authentication is enabled, users may authenticate using their authorized Microsoft organizational account.

Employee and Organizational Information

The application may process organization-provided information such as:

  • Organization name
  • Brand
  • Branch or region
  • Employee designation or role
  • Reporting structure
  • Team or manager information

This information is used to provide organization-specific access and functionality.

Incentive and Performance Information

To provide incentive management functionality, the application may process business-related employee information, including:

  • Proposed incentive amounts
  • Generated or acquired incentives
  • Approved incentive amounts
  • Incentive overrides
  • Incentive payout information
  • Target information
  • Target achievement status
  • KPI performance
  • Productivity information
  • Sales-related performance data
  • Historical incentive earnings
  • Performance categories
  • Achievement status
  • NPC and other business performance metrics

This information is primarily provided by or generated on behalf of the participating organization.

Authentication and Security Information

To provide secure access to the application, we may process:

  • Employee credentials
  • Authentication tokens
  • One-Time Passwords (OTP)
  • Login session information
  • Microsoft authentication information, where applicable

Passwords and authentication credentials are handled through appropriate authentication mechanisms and are used only for identity verification, authentication, and account security.

Technical Information

When you use the application, certain technical information may be automatically collected or processed, such as:

  • Device type
  • Operating system and version
  • Application version
  • Device identifiers where technically required
  • IP address
  • Login timestamps
  • Error and crash information
  • Application performance information
  • Diagnostic logs

This information may be used to maintain application security, troubleshoot technical issues, improve reliability, and support application performance.

How We Use Information

Information processed through Incentive Management may be used to:

  • Authenticate authorized users.
  • Provide secure access to organization-specific information.
  • Calculate and manage employee incentives.
  • Display incentive and earnings information.
  • Manage incentive approval and override workflows.
  • Monitor targets and target achievement.
  • Provide employee and team performance information.
  • Generate dashboards, trends, reports, and analytics.
  • Manage role-based access and permissions.
  • Support multiple organizations within the platform.
  • Maintain application security and prevent unauthorized access.
  • Diagnose technical problems and improve application performance.
  • Provide customer and technical support.
  • Meet applicable legal and regulatory requirements.

We process information only for purposes related to providing, securing, maintaining, and improving the Incentive Management platform and associated business services.

Multi-Organization Data

Incentive Management is designed to support multiple participating organizations.

Each authorized user is provided access based on their associated organization, role, and permissions.

Organization-specific information may include:

  • Employee information
  • Incentive structures
  • Incentive calculations
  • Performance information
  • Targets
  • Approval workflows
  • Brands and branches
  • Reports and analytics

Appropriate access controls are used to restrict users to information and functionality they are authorized to access.

Participating organizations may be responsible for providing and managing employee information processed through the platform.

How We Share Information

We do not disclose personal information except where necessary to operate the application, provide requested services, support participating organizations, comply with legal obligations, or protect the security of our systems.

Information may be shared with:

Your Organization

Information may be accessible to authorized representatives of the organization associated with your account, including administrators, managers, approvers, or other authorized personnel, depending on your organization's access-control structure.

Service Providers

We may use trusted technology and service providers to support functions such as:

  • Cloud hosting
  • Authentication
  • Application infrastructure
  • Notifications
  • Security
  • Error monitoring
  • Analytics and diagnostics

Such providers may process information only as necessary to provide their respective services and subject to applicable contractual and security obligations.

Legal Requirements

Information may be disclosed when required by applicable law, legal process, regulatory obligations, or valid governmental requests.

It may also be disclosed where reasonably necessary to protect the rights, security, or safety of users, organizations, the application, or others.

Microsoft Sign-In

The application may support Microsoft authentication for participating organizations.

When users choose to sign in through Microsoft, authentication-related information may be processed through Microsoft's authentication services.

The information received by the application depends on the permissions configured for the application and the user's organization.

Microsoft's processing of information is governed by its applicable privacy terms and policies.

Data Security

We take reasonable technical and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

These measures may include:

  • Secure authentication
  • Role-based access controls
  • Secure network communication
  • Access restrictions
  • Authentication token management
  • Security monitoring
  • Appropriate infrastructure security controls

However, no electronic transmission or storage system can guarantee absolute security.

Users are responsible for maintaining the confidentiality of their account credentials and should immediately report suspected unauthorized access.

Data Retention

We retain information only for as long as reasonably necessary to:

  • Provide the Incentive Management services.
  • Support the participating organization's business requirements.
  • Maintain required business and audit records.
  • Meet contractual obligations.
  • Resolve disputes.
  • Enforce agreements.
  • Comply with applicable legal or regulatory requirements.

Retention periods may vary depending on the type of information, the participating organization's requirements, contractual obligations, and applicable law.

Information may be deleted or anonymized when it is no longer required for its intended purpose, subject to applicable retention requirements.

User Rights and Data Requests

Depending on applicable laws and the relationship between the user and their organization, users may have rights regarding their personal information, including the ability to request:

  • Access to personal information
  • Correction of inaccurate information
  • Deletion of eligible personal information
  • Restriction of certain processing
  • Information about how personal information is processed

Because many user accounts and associated records are managed by participating organizations, some requests may need to be submitted through the user's employer or organization administrator.

Users may also contact us using the contact information provided in this Privacy Policy.

Account Deletion

Where applicable, users may request deletion of their account and associated eligible personal information.

Account deletion requests may be submitted through:

Email: support@tolaram.com
or through the applicable account-management functionality provided within the application.

Certain information may need to be retained where required for legal, regulatory, contractual, security, fraud-prevention, audit, or legitimate business purposes.

Where an account is managed by an employer or participating organization, the deletion request may also need to be coordinated with that organization.

Children's Privacy

Incentive Management is a business and workforce-related application intended for authorized organizational users.

The application is not intended for children under the applicable minimum legal age, and we do not knowingly design the service to collect personal information from children for consumer purposes.

If we become aware that information has been collected from a child contrary to applicable requirements, appropriate steps will be taken to address the matter.

Notifications

The application may provide notifications related to:

  • Incentive updates
  • Approval workflows
  • Performance information
  • Business notifications
  • Other organization-related activities

Users may be able to manage notification permissions through their device settings.

Analytics and Diagnostic Services

We may use technical monitoring, analytics, crash-reporting, or diagnostic services to understand application performance, identify technical issues, and improve reliability.

Where third-party services are used, information processed by those services will depend on the technologies integrated into the application.

Any such data practices must also be reflected accurately in the applicable App Store Privacy and Google Play Data Safety declarations.

Sale of Personal Information and Advertising

We do not sell users' personal information.

Incentive Management is a business application and does not use employee information for third-party behavioral advertising.

We do not use personal information collected through the application to build advertising profiles for users.

International Data Processing

Depending on the participating organization, hosting infrastructure, and service providers used, information may be processed or stored in countries other than the user's country of residence.

Where required, appropriate measures will be taken to protect information in accordance with applicable data-protection requirements.

Third-Party Services

The application may integrate with third-party platforms or technology providers necessary to provide certain functionality, such as authentication, cloud infrastructure, notifications, analytics, or technical monitoring.

Examples may include:

  • Microsoft authentication services
  • Cloud infrastructure providers
  • Push notification services
  • Application monitoring or crash-reporting services

The exact third-party services used may change as the platform evolves.

Third-party services may process information according to their respective privacy practices.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

  • Changes to application functionality
  • Changes in data-processing practices
  • New regulatory requirements
  • Security or operational improvements

When changes are made, the “Last Updated” date at the top of this Privacy Policy will be revised.

Where required, users may also be notified of material changes through appropriate channels.

Contact Us

For questions, concerns, privacy requests, or account-related data requests, please contact:

CompanyTOLARAM AFRICA ENTERPRISES LIMITED
ApplicationIncentive Management
Support emailsupport@tolaram.com
Address38 Eric Moore Road, Surulere, Lagos, Lagos 101227, Nigeria
CountryNigeria